On September 10, 2026, the Department of Housing and Urban Development (HUD) published a report by its own oversight entity, the Office of the Inspector General (OIG), evaluating the agency’s implementation of Build America, Buy America (BABA) requirements throughout HUD programs.

The Buy America Preference within BABA requires federal agencies to limit federal infrastructure spending unless the iron, steel, manufactured, and construction products used were domestically sourced in the U.S., which has proven infeasible for LeadingAge members developing new affordable housing units.

The report, titled “HUD Needs to Improve its Monitoring of the Buy America Preference of the Build America, Buy America Act,” called out HUD’s lack of compliance monitoring for BABA; OIG recommends that HUD designate an official responsible for overseeing BABA implementation and consistency across HUD program offices.

BABA is applicable to four HUD program offices, including the Office of Multifamily Housing Programs, which administers the Section 202 Supportive Housing for the Elderly program, as well as the Green and Resilient Retrofit Program (GRRP), both of which are subject to BABA requirements. Moving forward, the Office of Field Policy and Management will serve as the lead office for BABA compliance across HUD.

As part of the evaluation process, HUD’s Office of Multifamily Housing Programs (MFH) agreed to implement a policy for monitoring compliance with BABA, with implementation of compliance monitoring targeted for July 2027. The report also states that to date, MFH has not issued any waivers, despite LeadingAge members experiencing significant challenge with the requirements.

LeadingAge will continue to work with our members and HUD to improve the waiver process; in addition, LeadingAge continues to urge HUD and Congress to fully exempt affordable housing developments from the Buy America requirements because they are too difficult to execute and the original statute did not intend to BABA requirements to affordable housing.